On 15 July 2025, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) announced a civil settlement with a U.S.-based global brokerage firm, which had self-reported numerous U.S. sanctions violations under different sanctions programs. Most of the violations involved the brokerage firm’s provision of services to persons in comprehensively sanctioned jurisdictions. But the settlement also involved violations of more bespoke restrictions on U.S. persons, including the Non-SDN Chinese Military-Industrial Complex Companies List (“NS-CMIC”) investment restrictions and the Russia new investment ban under E.O. 14071. This is the first time that OFAC announced violations under these sanctions programs. The case shows the challenges of timely identifying and preventing sanctioned transactions in a complex sanctions landscape.
For further information, please contact:
Doug Davison, Partner, Linklaters
doug.davison@linklaters.com
